GATHERING, USE, AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION
General Website Users
“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that can be directly associated with a specific person. Like most website operators, the Company gathers Non-Personally-Identifying Information from users of the Website that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system, browser type, and the locations of the websites the user views before arriving at, navigating, and immediately after leaving the Website.
Although such information is not Personally-Identifying Information, it may be possible for the Company to determine a user’s Internet service provider, the geographic location of the visitor’s point of connectivity, as well as other statistical usage data, from the IP address. The Company analyzes Non-Personally-Identifying Information gathered from users of the Website to help the Company better understand how the Website is used. By identifying patterns and usage trends, the Company is able to design the Website to improve users’ experiences, both in terms of content and ease of use. From time to time, the Company may also release aggregated Non-Personally-Identifying Information gathered from Website users, for purposes such as publishing a report on trends in Website usage.
COMPANY USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.
We may use third-party advertising companies to display advertisements when you visit the Website. These companies may use information (not including any Personally-Identifying Information) about your visits to the Website and other websites that are contained in Web Cookies in order to provide advertisements about goods and services of interest to you. Using a tool created by the Network Advertising Initiative, you can opt out of several third-party advertising servers’ and networks’ Web Cookies simultaneously. If you would like more information about this practice and learn about your choices related to not having this information used by these companies, please follow the following links: http://networkadvertising.org/managing/opt_out.asp, http://preferences-mgr.truste.com/, or http://www.aboutads.info/choices/. Please contact us if you would like to know the identity of the third-party advertising companies we are currently using to display advertisements.
We may allow advertisers to choose the characteristics of users who will see their advertisements, and we may use any of the Non-Personally-Identifying Information we have collected (including information you may have decided not to show to other users, such as your birth year or other sensitive personal information or preferences) to select the appropriate audience for those advertisements. We do not identify you to the advertiser.
A “Web Beacon” is an object embedded on a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or email. The Company may use Web Beacons on the Website and in emails in order to count users who have visited particular pages or viewed emails, and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information. They are a technique the Company may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information, including a Web Cookie number, time and date of a page or email view, and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered, permitting you to accept or decline Web Cookies on an individual basis.
We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies together to inform, optimize, and serve advertisements based on your past activity on the Website. This may include Google Analytics for Display Advertising. The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/) and/or opt out from Google Analytics for Display Advertising or the Google Display Network by using Google Ads Settings (www.google.com/settings/ads).
Aggregated and Non-Personally-Identifying Information
We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies, in order to develop and deliver targeted advertising on the Website and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We may also share aggregated information with third parties, including advisors, advertisers, and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to the Website and the most popular features or services accessed. This information does not contain any Personally-Identifying Information and may be used to develop website content and services that may be of interest to you and other users, which may include targeted content and advertising.
Mobile Device Additional Terms
- Mobile Device. If you use a mobile device to access the Website or download any of our applications, we may collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information, and IP address.
- Geo-Location Information. Unless we have received your prior consent, we do not access or track any location-based information from your mobile device at any time while downloading or using our mobile application or our services. There may be exceptions, such as when it is possible for the Company to determine the geographic location of your point of connectivity from an IP address, in which case, we may gather and use such general location data.
- Push Notifications. We send you push notifications if you choose to receive them, letting you know when someone has sent you a message or about other service-related matters. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
- Mobile Analytics. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information, such as how often you use the application, the events that occur within the application, aggregated usage, performance data and from where the application was downloaded. We do not link the information we store within the analytics software to any Personally-Identifying Information you submit within the mobile application.
We may provide you the option to connect your account on the Website to your account on social networking sites for the purpose of logging in, uploading information, or enabling certain features on the Website. When logging in with your social network credentials, we may collect the Personally-Identifying Information you have made publicly available on the social networking site, such as your name, profile picture, cover photo, username, gender, age range, locale, friend list, and any other information you have made public. Once connected, other users may also be able to see information about your social network, such as the size of your network and your friends, including common friends. By connecting your account on the Website to your account on any social networking site, you hereby consent to the continuous release of information about you to us. We will not send any of your account information to the connected social networking site without first disclosing this to you. Each social network may further allow you to set privacy controls over your information on their system, and our collection of information will always follow such controls and permissions. This feature is subject to continuous change and improvement by us and each social networking site involved, and therefore, the available features and shared information are subject to change without notice to you.
We may use hyperlinks on the Website that will redirect you to a social network if you click on the respective link. However, when you click on a social plugin, such as Facebook’s “Like” button, Twitter’s “Tweet” button, or the Google+ icon, that particular social network’s plugin will be activated, and your browser will directly connect to that provider’s servers. If you do not use these buttons, none of your data will be sent to the respective social network’s plugin provider. For example, when you click on Facebook’s “Like” button on the Website, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the Website. Settings regarding privacy protection can be found on the websites of these social networks and are not under our control.
COLLECTION, USE, AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION
As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. The Company may collect a range of Personally-Identifying Information from and about Website users. Much of the Personally-Identifying Information collected by the Company about users is information provided by users themselves when (1) registering for our service, (2) logging in with social network credentials, (3) participating in polls, contests, surveys, or other features of our service, or responding to offers or advertisements, (4) communicating with us, (5) creating a public profile, or (6) signing up to receive newsletters. This information may include each user’s name, address, email address, and telephone number, and, if you transact business with us, financial information such as your payment method (credit card number, card type, expiration date, and/or other financial information). We may also request information about your interests and activities, gender, age, date of birth, username, hometown, and/or other demographic or relevant information as determined by the Company from time to time. Users of the Website are under no obligation to provide the Company with Personally-Identifying Information of any kind, with the understanding that a user’s refusal to do so may prevent the user from accessing certain Website features.
BY REGISTERING WITH OR USING THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THE “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION ABOVE.
USERS ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM THEIR VOLUNTARY DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION.
We may occasionally use your name and email address to send you notifications regarding new services offered by the Website that we believe you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. Generally, you may opt out of such emails at the time of registration or through your account settings, though we reserve the right to send you notices about your account, such as service announcements and administrative messages, even if you opt out of all voluntary email notifications.
The Company will disclose Personally-Identifying Information under the following circumstances:
- Marketing Communications. Unless users opt-out from receiving Company marketing materials upon registration, the Company may email users about products and services that the Company believes may be of interest to them. If you wish to opt-out of receiving such marketing materials from the Company, you may do so by following the unsubscribe link in the email communications, by going to your account settings (if applicable), or by contacting us using the contact information below.
- Third-Party Marketing Communications. Unless users opt-out from receiving marketing materials upon registration, the Company may provide users’ email information to third parties, so that those third parties may directly contact them about additional products and services. If you wish to opt-out of receiving such communications from third parties, you may do so by going to your account settings (if applicable), or by contacting us using the contact information below. Even after opting-out, you may continue to receive marketing emails from third parties to whom the Company already has provided your email information. You will be responsible for directly contacting such third parties to request cessation of further marketing emails.
- Third-Party Service Providers. We may share your Personally-Identifying Information, which may include your name and contact information (including email address) with our authorized service providers who perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting Website functionality and contests, sweepstakes, surveys, and other features offered through the Website. We may also share your name, contact information, and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions, but they are not permitted to share or use such information for any other purpose.
Changing Personally-Identifying Information and Account Termination
At times, we may review multiple users to identify problems. In particular, we may examine your Personally-Identifying Information to identify users who may be utilizing multiple user IDs or aliases. We may compare and review your Personally-Identifying Information for accuracy and to detect errors and omissions. We may use financial information or payment methods to process payment for any purchases made on the Website, enroll you in the discount, rebate, and other programs in which you elect to participate, identify and/or protect against possible fraudulent transactions, and otherwise as needed to manage our business.
GENERAL COLLECTION AND USE OF INFORMATION BY THIRD PARTIES
We take the security of your Personally-Identifying Information seriously and use reasonable electronic, personal and physical measures to protect it from loss, theft, modification, or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures.
We are dedicated to protecting all information on the Website to the best of our ability. However, you are responsible for maintaining the confidentiality of your Personally-Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or to your account. If you lose control of your account, you should notify us immediately.
The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain Personally-Identifying Information from anyone under the age of 13, unless or except as permitted by law. Any person who provides Personally-Identifying Information through the Website represents to us that he or she is 13 years of age or older. If we learn that Personally-Identifying Information has been collected from a user under 13 years of age on or through the Website, then we will take the appropriate steps to delete this information. If you are the parent or legal guardian of a child under 13 who has become a member of the Website or has otherwise transferred Personally-Identifying Information to the Website, please contact the Company using our contact information below to have that child’s account terminated and the information deleted.
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting that you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, the Website currently does not respond to DNT browser signals or mechanisms.